About this form:
This form is designed to fulfill the SEC brochure requirement (Part II of Form ADV), and to inform clients about fees and the services of Polaris Asset Management.
Fees:
Polaris Asset Management will charge for its services in three ways. Polaris Asset Management may be paid through profit sharing arrangements with private limited partnerships, though these fees will be a portion of the fees the manager earns, and will be based on performance. All fees will be disclosed, and these investments are for qualified investors only. We may also charge hourly for consultations. For others, the only fees charged will be for a percentage of assets under management. This will be called the asset management program. Fees for this program will be paid quarterly in arrears.
Services provided, termination agreement:
These may be found in the client agreement at the end of this document.
Types of clients:
Polaris Asset Management will provide investment advice for individuals, families, retirement accounts, Uniform Gifts to Minors accounts, trusts, foundations, charitable organizations, and corporations or partnerships or other business entities.
Types of investments:
Polaris Asset Management will offer advice on the following types of investments: over-the-counter securities, securities listed on the New York and American Stock Exchanges, U.S. government securities, interest in private limited partnerships, ADR's (listed shares carrying an interest in securities traded on foreign exchanges), exchange traded funds, and publicly traded limited partnerships.
Methods of analysis and risk of loss:
Polaris Asset Management will rely mainly on fundamental analysis of individual companies, though technical analysis, the companies' history of earnings, acquisitions, stock offerings, and rights offerings may also be considered. Additional factors to be considered in investing in closed-end mutual funds include lifeboat provisions, history of the funds' tender offers and rights offerings, net asset value, portfolio composition, management and custodial fees, and price history. Investing in securities involves risk of loss of capital.
Principal sources of investment information:
Polaris Asset Management will rely on financial publications and newspapers, web sites, corporate filings, outside broker/dealer research, prospectuses, conference calls, and broadcast and electronic news sources.
Investment strategies:
Polaris Asset Management will for the most part use long-term purchases in order to gain tax advantages for clients, though the company may at times use margin transactions, short term purchases, and short sales when such strategies seem appropriate.
Biographical Information:
The firm's principal, Robert Doggett, is a graduate of Brown University and the Graduate School of The University of Washington. He was born in 1951 in Houston, Texas. He has been a private investor for twenty-five years, managed friends and relatives' accounts for more than ten years, and taught English and Economics at Lakeside School in Seattle, Washington for over twenty years. He has served on the boards of The Friends of the University of Washington Libraries and The Seattle Shakespeare Company. He is also an Eagle Scout and a member of Phi Beta Kappa. He is not registered as a broker-dealer.
Other financial industry affiliations:
Robert Doggett does not anticipate having other financial industry activities or affiliations outside of Polaris Asset Management. All fee or profit-sharing arrangements will be fully disclosed to the client. This could change in future if Polaris Asset Management develops an asset relationship with another financial institution, though no relationship of this sort currently exists.
Custody and prepayment:
Polaris Asset Management will not take custody of client funds, nor will it require prepayment of fees by clients.
Review of accounts:
Reviews of accounts will be conducted on an ongoing basis either in person or by telephone. At year end each account will also be reviewed in writing. Polaris Asset Management will make itself available to clients for any specific questions regarding investment strategy or a particular security held in accounts. Clients will receive monthly statements from the broker/dealer where their accounts are held, and these statements will detail cash balances, dividend or margin payments, previous transactions, and other account activity. Privately held limited partnerships will provide the necessary K-1 forms to each client.
Discretionary trading power within accounts:
Polaris Asset Management will have discretion over names of securities to be bought and sold, the number of shares to be bought and sold, the broker/dealer to be used for transactions. Commission rates to be paid by the client will be determined by the broker/dealer. Polaris Asset Management will determine the primary custodian for client assets and will have the authority to transact business on behalf of client accounts. Polaris Asset Management will always strive to keep fees paid by clients to the absolute minimum.
Polaris Asset Management does not receive any products or services (so-called “soft dollar benefits”) in exchange for business from any broker/dealer. Polaris Asset Management does not negotiate lower commissions through “bunches” of trades, and will fully disclose to clients the potential advantages and disadvantages of directing transactions through broker/dealers of their own choice.
Non-assignment Clause
Client contracts cannot be assigned (sold, bartered, or traded) to another party.
Balance Sheet:
Polaris Asset Management does not and does not plan to have custody of client funds or securities. Polaris Asset Management will have broker/dealers deduct fees each quarter for asset management accounts.